LEZs: the figures that show why the issue could quickly become explosive



The news at the end of March for the French car industry should be marked by the examination of the bill on 'combating climate change and strengthening resilience to its effects', which proposes to introduce, by 2024, the concept of LEZ-m for cities with more than 150,000 inhabitants. Interpreted strictly, the intervention obligations placed on local politicians could lead to the exclusion of millions of vehicles from the fleet, and the authorities seem to be discovering this. A reality and an urgency that the "cognitive map" of public officials is still struggling to identify and integrate.

Autoactu already pointed out at the beginning of March that when Brussels tries to move from the obligations it places on manufacturers regarding the average emissions or consumption of the vehicles they put on the market (CAFE) to its long-term objectives (2050) defined in terms of carbon neutrality, this poses some serious problems.
Indeed, whether one focuses on the ultimate objective or on the intermediate objective set for 2030 at a -50% (likely to be rapidly corrected to -55%) of the carbon emissions of the vehicle fleet, it appears that this second way of posing the environmental question is not fully consistent with the first: the obligations in terms of CAFE defined to ensure that registrations are rapidly green-lit are not sufficiently demanding to ensure that the objectives assigned to the emissions of the vehicle fleet are achieved.
Paradoxically, for the downstream professions of the automotive industry, this late discovery of a cumbersome reality by industry and/or regulatory authorities should be a victory and is turning into a new cause for concern.
It should be a victory because, for years, the representatives of the downstream sector have been repeating that the automotive realities experienced by the French refer to the fleet with which they ensure their mobility and not only to the vehicles that interest the manufacturers, i.e. those that leave their factories.
In the same way, they insist on stressing that it is the fleet that emits, pollutes and is concerned by road insecurity, and on this basis they defend the idea that a reasonable car policy must be at least as interested in the fleet and those who manage it for households and companies that use it as in the registrations.
Therefore, the fact that, with the 2030 or 2050 carbon neutrality objectives as well as the LEZs, the public authorities are finally taking an interest in fleets should be a source of satisfaction in the form of a 'welcome to the real world of real people'.
Indeed, we know that the characteristics of new car buyers and the fleets they own are quite different from the 'average profiles'. This is the case for new car-buying households, which correspond to fairly narrow minorities that are richer, older and more urban than average. This is also the case for companies that are larger and more urban than average. 
Obviously, the distances between the average profiles of vehicle owners and those of vehicles purchased new are all the greater as the latter are in the minority compared to the former.
Since this has always been the case and since this disproportion is growing, the transition from registrations to fleets is increasingly perilous.
The current misguidedness of the public authorities on the issue of the LEZs shows us that this difficulty in building a bridge between registrations and the fleet is not only statistical or analytical but also very largely political: those who are bothered or worried about emissions are probably more like new car buyers than the average population. Therefore, making their wishes a priority justified by climatic or health emergencies is possible as long as we stick to the rhetoric, but risks becoming highly problematic if, as the introduction of the LEZs threatens to do, we draw the consequences by a policy of prohibiting the circulation of vehicles considered problematic.

The debates on the measures envisaged in Lyon and the remarks raised by the government's offer of micro-credit to support the purchase of clean vehicles by households unlikely to have access to bank credit show that this shift from registrations to fleets puts politicians over a chasm whose existence, if not its importance, they are discovering. They are beginning to realise this with the discussions in parliament of the Climate and Resilience Bill, which is due to be examined in public session from 29 March. 

Indeed, the bill on "combating climate change and strengthening resilience to its effects", which stems from the proposals of the Citizens' Climate Convention, proposes in one of its six titles entitled "Moving around" to introduce, by 2024, the concept of LEZ-m for cities with more than 150 000 inhabitants. 
As the website of "la banque des territoires" indicates, "absent from the files and press releases", "foresees that a decree will specify the conditions of application of the obligation to set up LEZs and, in particular, the methods according to which it is possible to derogate from this obligation, taking into account the small proportion of the population exposed to exceedances of air quality standards or the alternative actions put in place in order to comply with these standards as quickly as possible. It nevertheless stipulates that, in these zones, when air quality standards are not met, the restriction measures shall prohibit traffic : 
- no later than 1 January 2023 for diesel and similar vehicles with a date of first registration before 31 December 2000 and for petrol and similar vehicles with a date of first registration before 31 December 1996; 
- no later than 1 January 2024 for diesel and similar vehicles with a date of first registration before 31 December 2005; 
- by 1 January 2025 at the latest for diesel and similar vehicles with a date of first registration before 31 December 2010 and for petrol and similar vehicles with a date of first registration before 31 December 2005.
This means that the bill takes the LEZs out of the Paris region and very large cities where they were already a problem and potentially makes them a national reality in a very short time (three and a half years) with a very heavy direct impact on the fleet used by households and companies.
Thus, if we retain the provisions envisaged for 1 January 2025, which amount to authorising the use of vehicles only if they can display Crit'air stickers of at least level 2, we would exclude, according to the fleet demography models we have developed, 11.9 million vehicles (9.2 million diesel and 2.7 million petrol) out of the 41.7 million passenger cars in circulation, i.e. 28.5% of the fleet.
If, as is often suggested, we were to ban the use of diesel vehicles in 2030, this would mean that 28% of the cars in circulation would be excluded. 
Faced with the size of these figures, neither the politicians nor the administration can remain silent: the vehicles concerned by the bans envisaged in three years' time represent five (good) years of new car registrations and everyone has come to understand that the owners of the vehicles that are about to be banned are not precisely those who are likely to be concerned by the new car purchases in question: they have mostly bought old cars and have little reason to behave differently in the years to come; they will not, therefore, have clean vehicles in time and the aid that is supposed to enable them to change their behaviour to do so is unlikely to solve the problem.
It should be remembered that, in 2020, households bought 780,000 new cars, whereas they bought 5.6 million used cars, 45% (2,450,000) of which were 10 years old or more and 21.4% (1,203,000) 15 years old or more.
Of course, these three times more important purchases of new cars over 10 years old compared to old cars correspond to purchases of vehicles which, at 90%, will be excluded from the LEZs tomorrow, even though they were acquired because the households concerned needed them to ensure their mobility and had "envelopes" closer to 3,000 euros (which corresponds to the residual value of a 10-year-old vehicle) than to 27,750 euros (which corresponds to the average unit value of new vehicles sold in France in 2019 according to the ICCT).

As a form of awareness of this gap, the local authorities and the LOM propose car parks at the entrance to the LEZs so that the excluded can, despite their vehicles, access the cities concerned.

Seized by a vague remorse when they realise the subliminal discourse that this reinstatement of grants represents, the public authorities are putting on the agenda policies to help craftsmen first (without which the organic market would be less well stocked and houses or flats in gentrified neighbourhoods less easy to renovate) and then modest households to acquire clean vehicles
The subsidies for the purchase of electric vehicles are certainly there but, even if they were all combined, the gap of more than 24,000 euros would not be filled and, for craftsmen as well as for households, this problem would be coupled with that of access to credit.
So we are trying to do "something" and this is how the micro-credit offer mentioned by X. Champagne in Autoactu on Thursday came about. Champagne in Autoactu on Thursday.
At first sight, it seems judicious: the more than 2 million purchases of vehicles with crit'air 3, 4 or 5 stickers that were observed in 2020 could have been vehicles with 0, 1 or 2 stickers if the buyers had been able to access credit.
This is probably only true of a proportion of them, and it is undoubtedly undesirable that some of them should add this to their long list of problematic fixed charges, but even accepting the hypothesis does not resolve the issue. 
Indeed, the measure is not only intended to lead those populations who eat (old) Crit'Air 3, 4 or 5 bread to switch to Crit'Air 0, 1 or 2 buns, it is also intended that they eat organic buns and it excludes from the vehicles whose purchase would be eligible the Diesels (Crit'air 2) and, even, among the Crit'air 1, those which emit (in NEDC) more than 109g.
This means that if you are looking for a petrol car, if you want to stay under 10,000 euros, you will only be able to buy a category A car or a very small part of the recent range of B petrol cars.
The range of alternatives allowed in the LEZ does not exist. The gap is too big. It is unrealistic to try to close it so quickly, because the average age of the fleet is 11 years and it is being renewed very slowly. If we relate the 'usual' registrations of new cars in France (2 million) to the fleet as we estimate it on 1 January 2021 (41.1 million), the ratio is less than 4.87%.
This means that it takes between 20 and 21 years to renew the stock. This ratio will decrease as vehicles become more reliable, run less and households decide to give priority to other priorities in their budget choices.
These realities, which are well known to trade and maintenance-repair professionals, are what politicians are discovering. The measures they are proposing consist for the time being in making arrangements that are more a matter of denial than of realism.
In an optimistic scenario, it will be considered that it is a question of time and that the discovery, which is too recent, has yet to be fully assimilated. In a more sceptical scenario regarding the cognitive map of the elites, they will be left to maintain an untenable course until they have to pretend that they have adopted sustainable measures, or consider that there are not so many places where air quality standards are not respected, or give up checking whether the vehicles circulating in LEZs are those that are authorised.


The weekly column by Bernard Jullien is also on www.autoactu.com.

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